This week, I took part in a roundtable discussion about biobased products with my colleagues Kathleen Roberts and Dr. Rich Engler. Over the last several years, there has been a significant trend towards the use of renewable, bio-based chemicals. Although these chemicals often have similar, if not identical, functionalities as the non-renewable, fossil-based chemical that they are intended to replace, there are a number of regulatory challenges in bringing these to market. In this conversation, we discuss what these commercial challenges are, why the EPA has, in most cases, “pre ... read more >
January 10, 2019
“Dis-harmonization” of GHS
This week, I sat down with Karin Baron, a senior regulatory consultant here at Bergeson & Campbell and all around expert on chemical product labeling to discuss recent developments pertinent to the United States Hazard Communication Standard (HCS). These regulatory developments have been proposed to bring the HCS more in line with GHS, the Global Hazard Communication Standard. Karin unpacks this complex but really important area of the law and focuses on the aspirational and important goals of harmonization, in a way that focuses on the realities of a world that actually ensures ... read more >
December 13, 2018
TSCA and Stalled Innovation
Recently, we published a 3 part article with Bloomberg News entitled: New Chemicals Under New TSCA—Stalled Commercialization. This week, I sat down with Charles Auer, a Senior Regulatory and Policy advisor here at the firm, and Dr. Richard Engler, our Director of Chemistry, two of my co-authors on this article to talk about it.
Our thesis is simple: EPA’s interpretation of our brand new industrial chemical law, the Frank R. Lautenberg Chemical Safety for the 21st Century Act, signed into law in June 2016, needs to change. We believe that Congress never intended ... read more >
November 29, 2018
Confidential Business Information under TSCA
This week, I sat down with Dr. Richard Engler, our Director of Chemistry, to discuss Confidential Business Information (CBI). CBI is both a term of art under the Toxic Substances Control Act (TSCA) and can be understood broadly to be anything from trade secrets to you know, the secret sauce of a chemical formulation that makes a product profitable. In our conversation, we focused on how this concept of CBI functions under TSCA and how businesses need to handle CBI during the EPA’s chemical review process.
Rich is the perfect person to discuss the concept of CBI. Rich is 17-year veteran ... read more >
November 15, 2018
Chemical Regulation in the Middle East
This week, I sat down with Michael Wenk, one of our senior regulatory consultants, to discuss his new book Chemical Regulation in the Middle East. Michael’s book focuses on eight countries in the Middle East that have a combination of well developed and emerging chemical regulatory schemes. His book provides a comprehensive examination of the main chemical management laws in force for each particular country, and summarizes general trends and issues facing the region as a whole.
Michael has managed global regulatory affairs and product stewardship divisions at Fortune 500 chemical and ... read more >
October 31, 2018
Animal Testing and New TSCA
This week, I got to have a roundtable discussion with several of my colleagues about a Strategic Research Plan released by the EPA earlier this summer, outlining their approach to reduce and replace “vertebrate” testing. What we’re really talking about, of course, is animal testing. In keeping with the commitment outlined in 2016’s Toxic Substances Control Act (TSCA), the EPA proposes several so-called New Approach Methodologies, or NAMs, which they hope will be able to replace and reduce animal testing.
Weighing in on this hot topic are several of my colleagues: Dr. ... read more >
October 23, 2018
Introducing All Things Chemical
Hi, this is Lynn Bergeson of Bergeson & Campbell in Washington, D.C. I'm here to announce that we have launched a podcast. It's called All Things Chemical. And whether you are a lawyer in the chemical space, a scientist or a manager, or a CEO of a Fortune 50 chemical company, you will want to listen up. Starting November 1st we will be releasing a podcast every other week. We're going to be dealing with a whole host of really interesting issues including animal testing and alternatives to it, chemical regulation in the Middle East, the ever quirky and complicated area of ... read more >
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